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Posted

Have a client that merged a mp into a 401k PS plan. The MP vesting schedule is being maintained under the 401(k) PS plan. I need to allocate some unvested MP money. The 401(k) PS says to pay expenses first. How do you allocate the remaining forfeitures?

The only thing I found was an EP Determination Bulletin which references Rev Rul 2002-42 and cautions that before the MP Plan is merged, the plan should be amended to allocate forfeitures under a specific formula. That was apparently not not done and I do not have the old MP Doc. Current plan doc says that forfeitures should be used to pay expenses then allocated to ee's. Remaining NEC's should be allocated on the basis of comp.

How do I allocate the remianing forfeitures? Do I allocate on the basis of comp or allocate to only those employees with a MP balance?

Posted

I was able to get a copy of the old plan. The MPP says that forfeitures are to be used to reduce contributions. Does this mean that the forfeitures from the MPP are to reduce the contributions of the PSP?

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